May 30, 2023
The proposal entitled “Notice of Filing and Immediate Effectiveness of Proposed Rule Change to Amend the Clearing Agency Investment Policy” (SR-NSCC-2023-005) is significantly redacted which prevents public review making it impossible for the public to meaningfully comment on this proposal; so this proposal should be rejected on that basis alone. Segregating funds is a key protection against misappropriation of funds and customer protection. Deposits to the Participants Fund and Clearing Funds should not be commingled with each other or with general corporate funds of the Clearing Agencies. If the proposed changes are merely corrections, clarifications, and simplifications, then the proposed changes should be made available for public review instead of hidden in redacted exhibits. Obscuring proposed changes from public review, followed by approval and implementation, reduces the already dwindling public trust in both our SIFMUs and their regulators. Sincerely, Michael Shipe